STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

RICHARD SEEBORG, District Judge.

Pursuant to Local Rules 6-2 and 7-12, Plaintiffs EVERETT CASTILLO, LINDA CASTILLO, NICHOLAS DATTOMA, FREDA LANG, WENDY TRAN, and, STEVEN WILK ("Plaintiffs"), on behalf of themselves and all others similarly situated, and Defendant Seagate Technology LLC ("Seagate"), through their undersigned counsel, hereby stipulate as follows:

WHEREAS, on June 15, 2016, the Court granted the parties' stipulation to consolidate two actions related to Seagate's security practices: Castillo et al. v. Seagate Technology LLC, No. 3:16-cv-01958-RS (filed on April 14, 2016) and Dattoma v. Seagate Technology LLC, No. C5:16-cv-02136-RS (filed on April 21, 2016) (Dkt. No. 19);

WHEREAS, Plaintiffs filed their Amended Consolidated Complaint on June 28, 2016 (Dkt. No. 22);

WHEREAS, pursuant to the parties' stipulation and the Court's Order, Seagate's deadline to file its response is July 28, 2016 (See Dkt. No. 19 1:26-2:2);

WHEREAS, the Case Management Conference for this matter is currently scheduled for July 21, 2016, and the Joint Case Management Statement is due a week earlier, on July 14, 2016 (See Castillo Dkt. No. 9; Dattoma Dkt. No. 12);

WHEREAS, the parties agree that judicial efficiency would best be served by continuing the Case Management Conference until after Seagate has had the opportunity to analyze the allegations in the Amended Consolidated Complaint and to allow the parties an opportunity to meaningfully confer about the claims and defenses at issue and to brief any pleading motion;

WHEREAS, the parties agree that the Case Management Conference should be rescheduled to September 8, 2016 or a date thereafter convenient for the Court;

WHEREAS, the parties agree that all dates based on the initial case management conference, including the parties' deadline to meet and confer regarding initial disclosures, early settlement, the ADR process, and a discovery plan, as well as their deadline to file the Joint Case Management Conference Statement and Rule 26(f) report and complete initial disclosures, should be continued in accordance with the new case management conference date;

IT IS HEREBY STIPULATED AND AGREED by the parties, through their counsel, subject to the approval of the Court, that the July 21, 2016 Case Management Conference is continued to September 8, 2016 at 10:00 a.m. The parties shall meet and confer regarding initial disclosures, early settlement, ADR process selection, and a discovery plan—as well as file their ADR Certification and a Stipulation to ADR Process or Notice of Need for ADR Phone Conference—21 days prior to that date, on August 18, 2016. The parties shall file their Rule 26(f) Report, complete initial disclosures, and file a Case Management Statement 7 days prior to September 8, on September 1, 2016.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.